DTWFS

Last Updated: May'2025

DTWFS ("we," "us," or "our") is committed to safeguarding your privacy. This policy outlines how we collect, process, store, and protect your personal data in compliance with the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, and other applicable laws.

By using our website (dtwfs.odoo.com), purchasing products, or interacting with our services, you consent to the practices described herein.

1. Definitions

• Personal Data: Any information relating to an identifiable individual (e.g., name, email, payment details).
• Data Controller: [Your Brand Name], responsible for determining how and why your data is processed.
• Data Processor: Third parties processing data on our behalf (e.g., payment gateways, couriers).
• Consent: Freely given, specific, informed, and unambiguous agreement to data processing.

2. Data Collection & Categories

We collect the following data:

2.1 Personal Data Provided Directly by You

• Identity & Contact Data: Full name, email, phone number, billing/shipping address.
• Financial Data: Bank account details, wire transfer references, transaction history.
• Order Data: Product preferences, custom measurements, purchase history.
• Communication Data: Emails, chat logs, social media messages.
• Marketing Preferences: Opt-in/opt-out status for newsletters.

2.2 Automatically Collected Data

• Technical Data: IP address, browser type, device ID, operating system.
• Usage Data: Pages visited, time spent, clickstream patterns.
• Cookies & Tracking Technologies: See Section 9.

2.3 Data from Third Parties

• Payment Processors: Confirmation of wire transfers from your bank.
• Social Media: Public profile data if you interact with us via social platforms.
• Artisan Partners: Limited data for custom orders (e.g., regional sizing trends).

3. Legal Basis for Processing

We process data under the following UK GDPR lawful bases:

• Contractual Necessity: To fulfill orders, process payments, and deliver products.
• Legal Obligations: Tax reporting, fraud prevention, and regulatory compliance.
• Consent: For marketing communications (revocable at any time).
• Legitimate Interests: Website analytics, customer service improvements, and fraud detection.

4. Data Use Purposes

We use your data to:

1. Process orders, verify wire transfers, and ship products.
2. Communicate order updates, tracking, and customer support.
3. Personalize recommendations based on purchase history.
4. Improve website functionality via analytics (e.g., heatmaps, A/B testing).
5. Send promotional emails (with consent) about new collections, sales, or cultural events.
6. Comply with legal requests (e.g., HMRC audits, court orders).

5. Data Sharing & Third Parties

We share data only as necessary with:

5.1 Service Providers

5.2 Legal & Regulatory Disclosures

• Law Enforcement: If required to investigate fraud or illegal activity.
• Tax Authorities: To comply with VAT, customs, or import/export laws.

5.3 International Transfers

Data may be transferred outside the UK to:

• Cloud Servers: In the US/EU (covered by UK Adequacy Regulations).

We ensure safeguards such as:

• Standard Contractual Clauses (SCCs).
• Data Processing Agreements (DPAs) with third parties.

6. Data Retention

We retain data only as long as necessary:

7. Data Security

We implement technical and organizational measures:

• Encryption: SSL/TLS for data in transit; AES-256 for data at rest.
• Access Controls: Role-based access limited to authorized personnel.
• Regular Audits: Penetration testing, vulnerability scans.
• Employee Training: Annual GDPR and cybersecurity workshops.

8. Cookies & Tracking Technologies

We use:

• Essential Cookies: Session management, cart functionality.
• Analytics Cookies: Google Analytics, Hotjar.
• Marketing Cookies: Meta Pixel, Google Ads (opt-in required).

Manage preferences via our Cookie Consent Banner or browser settings.

9. Children’s Privacy

We do not knowingly collect data from individuals under 16. Parents/guardians may contact us to delete inadvertently collected data.

10. Automated Decision-Making

We do not use AI or profiling for decisions impacting legal rights.

11. Data Breach Notification

In the event of a breach posing risks to your rights, we will notify the UK ICO within 72 hours and affected users without undue delay.

12. Policy Updates

We may update this policy. Material changes will be:

• Posted on our website with a revised "Last Updated" date.
• Communicated via email (for active customers).